Chapter BKM404100
| Published date | 19 July 2017 |
| Record Number | BKM404100 |
| Court | HM Revenue & Customs |
| Issuer | HM Revenue & Customs |
There is an annual allowance of £25m available to groups or, where a group has only one banking company or the banking company is not in a group, to that banking company alone. The allowance exempts surcharge profits or CFC profits apportioned to a banking company from liability to the surcharge. Any unused allowance cannot be carried forward.
BKM402900 provides the definition of a group for the purpose of the banking surcharge and examples of how this applies where a company leaves a group.
A banking company can choose how much of its allowance should be used as a surcharge allowance against its surcharge profits and how much should be taken into account in its calculation of any CFC charge for the period. This information must be included in the banking company’s tax return and the total must not...
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